20210524Certificate of Attorney.pdf

Adam Lowney (ISB#10456)
McDowell Rackner Gibson PC 2:50
419 SW 11th Avenue,Suite 400
Portland,Oregon 97205
Telephone:[phone]
Facsimile:[phone]
Email:[e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)CASE NO.PAC-E-21-09INTHEMATTEROFTHEAPPLICATION)OF ROCKY MOUNTAIN POWER )ATTORNEY'S CERTIFICATEAPPROVALOFPOWERCOSTDEFERRAL-)CLAIM OF CONFIDENTIALITYDECREASEINRATES[ECAM])RELATING TO DISCOVERY
)RESPONSES
I,Adam Lowney,represent Rocky Mountain Power in the above captioned matter.
I make this certification and claim of confidentialityregardingthe response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power,through its response,is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code Section 74-101,et seq.and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233.Specifically,Rocky Mountain Power
asserts that attachment provided with the Company's response to PIIC 3 16'Supplemental contains
Company proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential information that the information contains Company proprietary information.
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I am of the opinion that this information is "Confidential,"as defined by Idaho Code
Section 74-101,et seq.and 48-801,and should therefore be protected from public inspection,
examination and copying,and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.
DATED this 24th day of May,2021.
Respectfully submitted,
By
Adam Lowney
Attorneyfor Rocky Mountain Power
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